Battery EPR for Online Sellers in 2026: The EU Batteries Regulation Explained

In short: Usually yes. If you sell electronics with batteries directly to consumers in another EU country, you are normally the battery producer there. Since 18 August 2025, you must register in each country and join a producer responsibility organisation. Where you have no local establishment, you also need an authorised representative.

Updated October 2026. This guide explains the extended producer responsibility (EPR) rules of the EU Batteries Regulation, Regulation (EU) 2023/1542, for online sellers. It focuses on sellers of electronics with built-in or bundled batteries. It summarises the rules as of October 2026 and links to official sources for each country.

Who counts as a battery producer if I sell online?

You are a battery producer in a country if you are the first to make batteries available there, including batteries inside your products. Selling by distance contract directly to end users in another country also makes you the producer in that country.

The Regulation's producer definition covers three main situations for online sellers:

• Manufacturers and brand owners: businesses that make batteries, or products containing them, and supply them under their own name or trademark.
• Importers and first distributors: businesses that first make batteries available on a national market on a professional basis.
• Distance sellers: businesses that sell batteries "by means of distance contracts directly to end-users" in a Member State. The Swedish Environmental Protection Agency quotes this part of the definition.

If you sell to a local importer or distributor instead, that business is usually the producer. Our guide to extended producer responsibility explains the general producer concept.

Do batteries inside electronics count?

Yes. Batteries built into electrical equipment and vehicles are covered by producer responsibility. Belgium's battery scheme Bebat confirms the rules apply whether batteries are "sold separately or incorporated in devices, light means of transport, or other vehicles".

This means a seller of phones, headphones, toys, e-bikes or power tools may have battery EPR duties. These sit alongside WEEE duties for the device itself. See What is WEEE? for the equipment side.

What changed on 18 August 2025?

The Regulation's EPR and waste management rules have applied since 18 August 2025. The old Batteries Directive 2006/66/EC applied until 17 August 2025, according to Germany's Federal Institute for Materials Research and Testing (BAM).

• Regulation in force: Regulation (EU) 2023/1542 entered into force on 17 August 2023. It has applied since 18 February 2024, with requirements phased in until 2031.
• EPR start: France's environment agency ADEME states that, from 18 August 2025, producers in all battery categories must fulfil their extended producer responsibility.
• Netherlands: the Human Environment and Transport Inspectorate (ILT) confirms the first EPR obligations under the Regulation started on 18 August 2025.
• Collection targets: in France, the collection target for portable batteries rises to 63% by 31 December 2027 and 73% by 31 December 2030.

The core EPR obligations are the same in each country. You register with the national producer register, join a producer responsibility organisation (PRO) or approved individual scheme, report quantities and pay fees.

Which battery categories apply to my products?

The Regulation uses five battery categories, replacing the three categories of the old Directive. You usually register and report separately for each category you place on the market.

• Portable batteries: sealed batteries weighing 5 kg or less that are not designed specifically for industrial use. Most batteries in consumer electronics fall here.
• Light means of transport (LMT) batteries: sealed batteries weighing 25 kg or less, designed to power wheeled vehicles such as e-bikes and e-scooters.
• Starting, lighting and ignition (SLI) batteries: batteries designed to supply power for starting, lighting or ignition in vehicles.
• Industrial batteries: batteries designed for industrial uses. Any battery over 5 kg that fits no other category is treated as industrial.
• Electric vehicle (EV) batteries: batteries designed to power traction in hybrid or electric road vehicles.

Germany's register, stiftung ear, describes the change as "3 types of batteries turn into 5 categories of batteries". Producers there must join a producer responsibility organisation for each battery category.

Do I need an authorised representative for batteries?

Yes, if you sell batteries by distance contract to end users in an EU country where you are not established. You must appoint an authorised representative for extended producer responsibility in that country. This applies to sellers from other EU countries and from outside the EU.

• Sweden: the Swedish EPA states that distance sellers established in another Member State or a third country need an authorised representative for EPR.
• Germany: foreign producers without a German branch have needed an authorised representative since 18 August 2025, according to stiftung ear.
• Belgium: Bebat states that the representative must be a person established in Belgium with a Belgian company number.
• Austria: foreign distance sellers must appoint an authorised representative. The representative registers on the EDM portal and submits a certified power of attorney to the ministry.

The representative takes over the producer's EPR obligations in that country, such as registration, reporting and scheme membership. A producer already established in a country cannot appoint one there, according to the Swedish EPA.

Is the authorised representative rule being suspended?

Not as of October 2026. On 10 December 2025, the Commission proposed suspending the rule in Article 56(3) of the Batteries Regulation until 1 January 2035. The proposal only covered producers established in another EU Member State.

On 24 June 2026, the Council said it had discontinued negotiations on this proposal and a parallel packaging proposal. Until any change is adopted, the obligation applies. Non-EU sellers were never covered by the proposed suspension.

What labelling and marking rules apply, and when?

Battery labelling under the Regulation is being phased in. Some requirements already apply, and others start in 2026 and 2027.

• CE marking: batteries placed on the EU market carry the CE marking, which indicates conformity with the Regulation.
• Separate collection symbol: all batteries must bear the crossed-out wheeled bin symbol for separate collection, according to Bebat.
• Cadmium and lead symbols: batteries containing more than 0.002% cadmium or 0.004% lead must carry the relevant chemical symbol.
• General information label: from 18 August 2026, producers and importers must affix a label with general battery information to all batteries, according to Bebat.
• QR code: from 18 February 2027, all batteries must be marked with a QR code, according to Bebat.

Labelling is a product requirement, separate from EPR registration. Check the requirements in Article 13 and Annex VI of the Regulation with your manufacturer or a testing body.

What do marketplaces and fulfilment providers check?

Some countries require marketplaces or logistics providers to check battery registrations. In Germany, the law stops retailers and fulfilment providers from handling batteries of unregistered producers.

• Germany: under section 4 of the Battery Law Implementation Act (BattDG), retailers may not supply batteries from producers that are not properly registered. Fulfilment providers may not store, pack, address or ship them.
• Germany (retailer liability): section 3 BattDG treats a retailer that knowingly or negligently supplies unregistered producers' batteries as a producer itself.
• Belgium: according to Bebat, online marketplaces may only allow producers who can show they are affiliated with Bebat. Marketplaces also send regional authorities an annual overview of producers active on their platform.
• Spain: MITECO's guidance under Royal Decree 106/2008 says producers' registration numbers must appear on invoices and, for distance sales, on the sales website or platform.

For how marketplaces split tax and compliance roles more generally, see tax, VAT and EPR for European expansion.

How do the national battery registers work?

Each country runs its own producer register and approves its own PROs. The list below covers the main markets where we could confirm the rules from official or national scheme sources.

• Germany: producers register with stiftung ear in each of the five categories and must join a producer responsibility organisation (OfH) per category. The BattDG has applied since 7 October 2025. Registrations without OfH participation were revoked after the 15 January 2026 deadline, and selling without a valid registration is an administrative offence. See EPR in Germany.
• France: battery producers selling in-store or online must fulfil EPR through an accredited PRO. ADEME lists Batribox and ecosystem (categories 1 to 5) and Recycler Mon Véhicule (category 5). Their accreditation runs from 18 August 2025 to 31 December 2030. See EPR in France.
• Spain: MITECO guidance under Royal Decree 106/2008 says producers must notify the state Integrated Industrial Register (Registro Integrado Industrial). They report quantities annually and can comply individually or through a collective scheme. See Spanish EPR rules.
• Italy: producers and collective schemes register in the national register of battery producers, held by the Chambers of Commerce. Registration applies whatever sales technique is used, including distance selling.
• Netherlands: the ILT checks whether battery producers and importers have registered with Rijkswaterstaat or joined a producer organisation.
• Austria: foreign distance sellers must appoint an authorised representative, who registers on the EDM portal with a certified power of attorney in German or English.
• Sweden: producers register with the Swedish EPA before making batteries available and receive an EPR number starting "SEBATT". Three PROs are authorised: Batterikretsen, Batteriretur Sverige and FoRetur.

National implementing laws are still changing in some countries. Check each register's current guidance before you start selling.

How do I get compliant step by step?

Start with your product list and sales countries, then work through each national register. Most sellers follow the same sequence.

1. Map your batteries: list every SKU that contains or ships with a battery, with its category, chemistry and weight.
2. Map your sales: list each country where you sell directly to end users, including marketplace sales.
3. Confirm your role: check whether you, an importer or a distributor is the producer in each country.
4. Appoint representatives: sign a mandate with an authorised representative in each country where you are not established.
5. Register and join a PRO: register in each battery category and join an approved scheme.
6. Share numbers: enter your registration numbers in marketplace accounts and, where required, on invoices and websites.
7. Report and pay: report quantities on each country's schedule and keep SKU-level records.

Our article on operationalising producer responsibility covers SKU-level data. Taxually's EcoTax covers EPR registration and reporting for batteries, packaging and WEEE in Germany, France and Spain.

Sources

• EUR-Lex: Regulation (EU) 2023/1542 on batteries and waste batteries
• European Commission: Batteries
• European Commission: COM(2025) 982, proposal to suspend authorised representative rules
• Council of the EU: press release, 24 June 2026
• stiftung ear: EU Batteries Regulation information for producers
• stiftung ear: BattDG enters into force (7 October 2025)
• stiftung ear: New battery rules fully in force (January 2026)
• BAM product contact point: Batteries legislation
• German Environment Agency (UBA): Batteries Regulation and stiftung ear
• Gesetze im Internet: Batterierecht-Durchführungsgesetz (BattDG)
• ADEME: Batteries EPR channel (BAT)
• MITECO: Obligations under battery legislation (Spain)
• Chamber of Commerce Como-Lecco: National register of battery producers (Italy)
• ILT: Collection and recycling of batteries (Netherlands)
• Austrian Business Service Portal (USP): Authorised representatives for batteries
• Swedish EPA: Producer responsibility for batteries
• Bebat: The European Battery Regulation 2023/1542
• Bebat: Meaning of symbols and labelling on batteries
• Bebat: Authorised representative for EPR